ML20081K880
| ML20081K880 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 06/26/1991 |
| From: | Woodard J ALABAMA POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9107020092 | |
| Download: ML20081K880 (4) | |
Text
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, eiw 3. . w . r June 26, 1991 10 CFR 2.201 Docket Nos. 50-348 50-364 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Vashington, D. C. 20555
SUBJECT:
Reply to a Notice of Violation J. M. Farley Nuclear Plant NRC Inspection of April 24-26, 1991 and May 8, 1991 RE: Report Number 50-348, 364/91-10
Dear Sir:
This letter refers to the violation cited in the subject inspection reports. The violation states:
" Unit 1 Technical Specifications, section 6.8.1, state in part that written procedures shall be established, implemented and maintained covering the applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33, Revision 2, 1978.
Administrative Procedures (AP) FNP-0-AP-52, Equipment Status Control and Maintenance Authorization, Revision 16, section 7.7.1 requires the maintenance persenne' performing the work to follow the work sequence specified.
Administrative Procedure FNP-0-AP-14, Safety Clearance and Tagging, Revision 11, estnblishes the administrative control to prevent operation of systems or components when such operation might cause personnel injury or equipment damage.
Administrative Procedure AP-16, Conduct of Operstions - Operations Group, Revision 21, sections 3.2.9.1 and 3.2.9.10 describes in part the responsibility of the shift supervisor in controlling activities of all personnel assigned to his shift.
Radiological Control Procedure FNP-0-RCP-0, General Guidance to HP Personnel, Revision 21, section 6.13 provides the administrative guidelines for the control of incore detector movement with personnel at the seal table / drive anits.
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O U. S. Nuclear Regulatory Commission Page 2 Contrary to the above, the licensee failed to follow procedures, failed to have adequate procedures, and failed to prevent deficient conditions:
- 1. Procedure FNP-0-AP-14 requires the shatt supavisor to issue hold tags to prevent operation of systems or cimponents when such operation might cause personnel injury or equipment damage. Also, procedure PHP-0-AP-52, section 7.7.1 specifies that the maintenance individual performing the work shall follow the work sequence specified in the work package. On April 16, 1991, the shift supervisor did not issue a clearance / hold tag when he instructed contractor personnel to close valve 01P16V514 due to a possible personnel safety concern. Additionally, contractor personnel closed the wrong valve (Service Vater train supply valve 01P16H53084A) causing a loss of service water to the containment coolers and subsequent loss of control room ventilation.
- 2. Procedure PNP-0-AP-52, section 7.7.1 specifies that the maintenance individual performing the work shall follov the work sequence specified in the work package. On April 21, 1991, contractor personnel performed an unauthorized step (step 2) of the work sequence while performing activities associated with Haintenance Vork Request (HVR) number 237?43 Unit 1. The error resulted in the inlet and outlet service water lines for the "A" containment cooler not being properly flanged. This created a potentially unisolable flow path.- The shift supervisor specified on the MVR that only step one of the work sequence should be performed.
- 3. Procedure FNP-0-AP-16, sections 3.2.9.1 and 3.2.9.10 stipulate in part that operation supervisors are responsible for the performance of all personnel assigned to their shift who could affect plant safety and that they are responsible for assuring the facility is operated safely within the requirements of the license, and Technical Specifications.
On April 23, 1991, the licensee failed to maintain plant control by either establishing a boundary between the work area and connecting systems and/or stipulating that only one valve shall be worked at a time while performing maintenance activities associated with Haintenance Votk Requests 219177, 232715, 219178, 219176, 219175 Unit 1. In performance of these work requests, electricians performed valve manipulations creating an unauthorized flovpath from the Reactor Vater Storage Tank to the containment sump, allowing approximately 4500 gallons to drain to the sump.
o U. S. Nuclear Begulatory Commission Page 3 l 1
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- 4. Procedure FNP-0-RCP-0 section 6.13.7 specifies that ,
continuous phone communications shall be established between !
personnel at the drive units and personnel guardirig the j incore drive controls in the control room when detectors ate '
to be moved with personnel in the containment. On May 5, 1991, the licensee failed to established communications as specified while performing maintenance activities on the "A" l incore detector per HVR 202659 vith licensee personnel performing monitoring activities inside Unit I containment.
This is a Severity bevel IV violation (Supplement 1)."
Admission or Denial The above violation occurred as described in the subject repot t.
Reason for Violation
- 1. Personnel error - The Shift Supervisor failed to control system ,
boundaries in accordance with established procedure in that he authorized non-operations personnel to manipulate a boundary valve.
- 2. Personnel error - The workers did more work than was authorized on the HVR.
- 3. Personnel error - The Shift Supervisor failed to adequately conttol work activities in that he did not release the work in a manner that prevented the valves from being opened at the same time.
- 4. Personnel-ertor - The llealth Physics Foreman failed to ensure that the-incore detector drive box and seal table areas were secure prior to allowing the "A" incore drive to be checked for proper operation, lie failed to recognize that FNP-0-RCp-0 should have been used for guidance in this situation.
Corrective Action.Taken and Results Achieved
-1. The valve was opened which restored service water flov.
- 2. A blind flange was installed to resteto system integrity.
- 3. The valves were closed which stopped water draining to containment.
- 4. Personnel' vere removed from the seal table area. The incore detectors vere inserted into the storage location and the electrical-power for the incore detector system was tagged out.
Corrective Steps To Avoid Further Violations The following specific actions have been taken to address each event:
- 1. All Shift Supervisors have been instructed on following existing procedures when establishing system boundaries. The shift Supervisor involved in this event has been disciplined for fallute to follow procedure.
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, U. S. Nuclear Regulatory Co.? mission Page 4
- 2. The work supervisor and the workers have been disciplined for their failure to follow the work sequence.
- 3. The Shift Supervisor involved in this event has been disciplined for his inadequate control of these work activities. All Shift Supervisors vill be reinstructed on the importance of considering system and plant effects when vork is being released.
- 4. All Health Physics Foremen vill be reinstructed on adhering to FNP-0-RCP-0 when developing Radiation Vork Permits for controlling maintenance and operation of the incore detector system. This incident vill be discussed with each Health Physics crew.
In addition to the specific actions listed above, the following general actions have been takent Plant personnel have been made aware of these and other examples of personnel errors through group meetings, plant safety meetings, memos to plant personnel and information in the plant nevsletter. Personnel vere encouraged to consider what they could do to prevent these types of events. Personnel vere also cislienged to do their daily jobs in a manner that vould prevent these types of errors.
Plant management and supervision vere directed by the General Manager - Nuclear Plant to increase the amount of time they spend monitoring and directing plant activities.
An independent review of these events is being conducted to determine the root cause of these events and to determine if any common cause/ factors exist.
Date of Full Compliance August 15, 1991 l Affirmation l
l I affirm that this response is true and complete to the best of my knowledge, information, and belief. The information contained in this letter is not considered to be of a proprietary nature.
Respectfully submitted, k
kb m JQ D) Voodard JDV/BHVimaf8.19 cc Mr. S. D. Ebneter Mr. S. T. Hoffman Mr. G. F. Maxwell
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